Child Protection Policy

Safeguarding and Child Protection Policy

Last reviewed May 2025, by Steve Gregson

Contents

1. Definitions and Principles

2. Responsibilities

3. Code of Conduct

4. Management of projects and activities involving children or young people

5. Chaperones and Licenses

6. Recruitment

7. Criminal Convictions and DBS

8. Communication

9. Photography, Videos, and Digital

10. Specific Safeguarding Issues

11. Reporting and Referring Procedures

1. Definitions and Principles

Steve Gregson Photography acknowledges its responsibility to protect the best interests and safety of children and young people and has safeguards in place that ensure their welfare and keep them safe from harm.

This policy document specifically reflects our duty to protect children, as defined by the

Children Act 2004 as someone who is under the age of 18. Throughout this policy, we use

the term ‘young people’ to refer to all those under 18. In certain instances, those over 18

may come under the remit of this policy e.g. Further Education and Higher Education

students.

The policy applies to anyone working on behalf of Steve Gregson Photography, referred to throughout the document as ‘staff’. This includes but is not limited to employees,

volunteers, and freelance contractors.

Safeguarding and Child Protection is defined for this policy as:

- Protecting children and young people from maltreatment

- Preventing impairment of children’s health and development

- Contributing to ensuring that children and young people grow up in circumstances

consistent with the provision of safe and effective care

Taking action to enable children and young people to have the best outcomes.

We are committed to the following principles:

- The welfare of children and young people is paramount

- All children and young people have the right to a safe and positive working

environment

- Children and young people, without exception, have the right to protection from

abuse or harm regardless of gender, ethnicity, disability, sexuality, or beliefs

- We recognise that some children and young people are additionally vulnerable,

whether this be because of previous experience, dependency, protected

characteristics, or other reasons

- Children and young people have the right to be respected, valued, and listened to

- Allegations of abuse or harm towards children and young people are to be taken

seriously in every instance

This policy seeks to uphold these principles by detailing code of conduct, guidelines, and

procedures that protect children and young people and safeguard their welfare.

2. Responsibilities

Steve Gregson Photography as a company and employer is responsible for:

- Implementing and strictly upholding a safeguarding policy to which all staff must

acknowledge and adhere

- Enforcing compliance with this policy as necessary

- Ensuring this policy document is shared with all staff working on behalf and with

Steve Gregson Photography at any time

- Ensuring that safeguarding training and information is provided when appropriate

- Carefully following all reporting and referring procedures as detailed in this policy

- Providing effective management of staff through effective line management,

support, and training

- Ensuring all projects undertaken adhere to the safeguarding policies before

undertaking them

- Following the procedures for recruitment of staff who work with children and young

people as detailed in this policy

- Ensuring that all staff working directly and closely with children and young people

will undergo a DBS check, if not previously acquired

- Undertaking safeguarding risk assessments for projects and activities involving

children and young people

- Developing and implementing this policy in conjunction with staff across the

organisation

- Carrying out or delegating to appropriate staff within the organisation the necessary

action to ensure that Steve Gregson Photography’s employer responsibilities are upheld e.g. organising training, requesting DBS checks, completing licensing processes, liaising

with the Company Manager on chaperone arrangements

- Collecting and managing safeguarding data and records for activities across the

company and its work/projects

- Managing complaints and allegations in the format detailed in Procedures in this

policy

- Being the first point of contact for all issues regarding Safeguarding and Child

Protection for both staff, agencies, children, and parents or carers

All staff are responsible for:

- Read, respect, and adhere to this Safeguarding and Child Protection Policy

- Act in accordance with the policy and acknowledge that failure to do so will be

addressed through disciplinary action and procedure

- Specific staff will have responsibilities identified in the safeguarding risk assessment

carried out for specific projects and activities

- Abide by the Code of Conduct

3. Code of Conduct

Staff will always:

- Treat everyone with dignity and respect

- Set an example you wish others to follow

- Treat all children and young people equally

- Build mutual trust and empower children and young people to contribute to

decision making

- Follow NSPCC recommended rations between adults and young people for

meetings and activities (these are: 4-8 years, 1 adult to 6 children; 9-12 years, 1

adult to 8 children; 13-18 years, 1 adult to 10 children)

- Respect children and young people’s right to personal privacy and confidentiality

- Avoid unacceptable situations within a relationship of trust

- Allow a working environment where children and young people can talk about any

concerns they may have

- Remember someone else might misinterpret your actions, no matter how well- intentioned

- Maintain an open-door policy on all activity involving children and young people

- Challenge inappropriate behaviour and language and encourage children and

young people to do the same

- Take any allegations or concerns of abuse seriously and report to Steve Gregson Photography as soon is practicable

Staff will never:

- Form a relationship with a child or young person that is an abuse of trust

- Engage in inappropriate behaviour or contact – physical, verbal, sexual, digital,

including on social media

- Make suggestive remarks or threats to a young person

- Use inappropriate language – verbally, writing, phoning, email, or online

- Let allegations, suspicions, or concerns about abuse go unreported

- Carry out tasks for which they are not trained (e.g. first aid, technical). This includes

taking on the responsibilities of Steve Gregson without communication.

Exceptionally, one-to-one contact will be unavoidable and in such cases staff will:

- Make sure it is for a short a time as possible

- Ensure you remain accessible to others

- Tell someone where you are going, what you are doing, and why

- Try to move with the child or young person to areas where there are more people

Try to avoid unnecessary physical contact

The positive use of touch is part of normal human interaction and may be appropriate in a

range of situations in theatre, such as:

- Giving guidance to a child or young person, such as how to perform a movement or

action

- Providing emotional support, for example placing an arm around a distressed child

- Providing first aid

Touch between young people in a scene

Staff will use appropriate care when touching young people and will be sensitive to those

children for whom touch may not be appropriate. Staff will always ask permission before

touching a child or young person and will provide alternatives where required.

4. Management of projects and activities involving children or young people

Risk Assessments

All projects and activities involving children or young people should be assessed for

safeguarding risks and responsibilities. All those involved in delivering the activity should

be familiar with these risk assessment actions. At the start of every new activity or new

location, Steve Gregson should work with those delivering the activity to ensure an appropriate risk assessment is in place.

The Safeguarding risk assessment does not replace or supersede any other Health and

Safety risk assessment but should be considered in conjunction with it.

The Risk Assessment should cover:

- Maximum participant numbers and minimum ratios for staff supervision, taking into

account the nature of the activity and the ages and needs of those involved

- Contingency arrangements should a member of staff be unavailable

- Medical emergencies and allergies, including access to first aiders

- Registration of participants, accounting for them at all times, and actions to take in

the event that a young person is not accounted for

The safe dispersal of young people at the end of the activity

Supervision of Children and Young People

Making arrangements for the proper supervision of children and young people is one of

the most effective ways of minimising opportunities for children and young people to

suffer harm of any kind whilst in our care. A child or young person is considered to be in

our care when they have been invited into any space where we have planned an activity for

them, such as workshops, rehearsals, meetings, or tours.

Children and young people should be supervised by staff who have:

- Relevant skills to conduct the activity – especially if it involves activities that involve

a higher degree of risk (e.g. stage fighting, technical etc.)

- The correct approach and demeanour to work with the group – in particular groups

that are particularly vulnerable such as those with additional needs or younger

children

- A commitment to upholding Steve Gregson Photography’s policies

- Knowledge and initiative to respond to emergency situations

Adults supervising young people must:

- Meet our requirements around DBS checks (see 7.)- Follow the risk assessment regarding supervision ratios, and not leave young

people unsupervised

- Know where young people are at all times, taking registers as appropriate

- Not leave young people unsupervised at any venue, whether it be indoors or out

- Not allow young people under the age of 16 to leave the building at breaks or

lunchtimes without the prior written consent of parents or carers

- Not take young people off the premises without the prior written consent of parents

or carers

- Not film, photograph or allow filming or photographing young people without the

written consent of parents or carers

Allow the use of any technical, specialist or dangerous equipment without a risk assessment and the constant supervision of an appropriately skilled adult

- Not allow dangerous behaviour by young people

- Not overlook or fail to challenge inappropriate behaviour by young people such as

bullying or inappropriate remarks

Adults supervising children or young people must ensure they leave safely. This includes:

- Establishing whether a child or young person is to transport themselves or be

collected by a parent or carer, and waiting with young people until they have safely

left the premises

- Attempting to contact a parent or carer if the child or young person has not left

safely

- Organising a taxi for a child or young person if there is a concern about them

travelling alone – every effort should be made to contact parents or carers to

confirm these arrangements

- Transporting a child or young person to safety, if accompanied by a second

responsible adult, and the car/driver is covered by business insurance

5. Chaperones and Licenses

The involvement of children under the age of 16 in performances is regulated by the

Children’s and Young Person’s Act 2014. Basic rule-of-thumb guidance is given below but

the full regulations must be checked before going ahead with a performance involving

children under the age of 16.

If young people will not be missing school, and will perform for less than four days, the

Local Authority can grant a Body of Persons Approval to an organisation to cover specific

productions. All Youth Theatre performances, holiday projects and one-off events should

be approved by relevant local council in this way. No such performance should take place

without the appropriate licenses being in place.For projects where young people will perform for more than four days and/or will miss school, each child will need to be licensed to perform by their Local Authority. Obtaining this license/ permission is not the responsibility of Steve Gregson Photography.

Obtaining a licence is dependent on the child’s place of education (e.g. school or parent/carer if home-schooled) giving permission for them to be absent for the required time. Any production in which licensed young people perform must also have the required number of chaperones licensed by their Local Authority.

6. Recruitment

Safe recruitment and selection practice is vital in safeguarding young people. Steve Gregson Photography recognises and takes seriously its responsibility to adopt practice which minimises risks to young people by ensuring that measures are in place through this practice to deter, reject or identify people who might abuse young people or are

unsuitable to work with them.

When appointing employees who will be working with young people, we will:

- Seek previous experience working safely with children or young people by stating

so in job descriptions

- Interview all candidates face-to-face, either in-person or on Zoom

- Obtain a DBS check where appropriate in line with our policy

- Question those who will be working with young people on their approach to

safeguarding

- Question any unexplained gaps in a potential employee’s employment history

- Provide a full induction, including supervision and guidance

- Continuously assess their suitability to work with young people throughout their

employment and take immediate disciplinary action if this is ever in doubt

7. Criminal Convictions and DBS

We will carry out an Enhanced DBS check for any additional staff working for Steve Gregson Photography as appropriate to each project if working on a show with young people.

Rehabilitation of Offenders

The Rehabilitation of Offenders Act 1974 requires that people applying for positions which

give them ‘substantial, unsupervised access on a sustained and regular basis’ to children

under the age of 18 years must declare all previous convictions which are then subject to

police checks. This includes potential volunteers and self-employed people such as

freelance practitioners. They should also be required to declare any cases pending against them. Applicants should be reassured that any information will be treated in confidence and will not be used against them unfairly.

Disclosure and Barring Service (DBS) checks

Training and supervising young people is a regulated activity. Steve Gregson Photography is therefore entitled and required to check anyone working for Steve Gregson, that those working with young people are safe to do so. This means obtaining a DBS check.

We recognise that other roles will involve occasional contact with young people in public

spaces and infrequent supervised contact. We do not routinely require a DBS check in

these circumstances, but if a role changes or tasks involve working frequently, regularly, or unsupervised with young people, a DBS check will be required.

If an applicant discloses on their form the existence of a prior conviction, Steve Gregson must be informed. The existence of a conviction does not automatically exclude someone from the recruitment process.

We do not keep copies of DBS certificates, in accordance with data protection rules. We

note the number of the certificate and the date of issue. We consider a date of issue within the last three years to be acceptable. If the date is earlier than three years, we will request a new DBS check for that individual.

Any concerns regarding a DBS check will be referred to Steve Gregson in the first instance.

8. Communication

Telephone

We recognise that young people will often prefer to communicate by mobile phone and

text message. However, in no circumstances should staff share their personal phone number with a young person or send/receive texts from young people using their personal

mobile phones.

Staff will, on occasion, be required to email young people. In all cases, staff should use

formal language to avoid any misunderstanding on the part of the recipient and keep a

copy of the correspondence if it relates to a safeguarding issue. In all cases, Steve Gregson must be cc’d or bcc’d into the email.

Social media

If a young person contacts a staff member directly through social media, staff should

exercise caution to ensure communication is limited and professional.

Staff are advised to protect themselves and to review their privacy settings and to keep

personal information private.

Staff should also treat any inappropriate messages or content they become aware of in line with this policy, including challenging inappropriate behaviour or referring any cause of concern. Any concerns should be referred to Steve Gregson.

9. Photography, Videos, and Digital

Photography

Written Parent/Carer consent is required for all photography or video recording of a child

or young person. This should be obtained through registration forms or contracts for

engagement at the commencement of each project. Photographs or videos of children or

young people will be stored in a designated folder that is only accessible by designated

staff.

Zoom

Steve Gregson Photography identifies Zoom as the primary tool for conducting meetings and sessions online. This policy thus details a distinct code of conduct for using Zoom with children and young people.

Code of conduct for Zoom:

1. At least one DBS checked staff member will be in the session

2. No 1-1 calls with children or young people should take place

3. All staff should work from a location that should be as neutral/professional as

possible wearing appropriate clothing, even if you don’t think you will be seen

4. The session leader should check that all participants are in a suitable and safe

environment for the activity you plan to deliver

5. No recording or photography should take place unless it is by the host and with

permission of the participants

6. The session leader should establish any additional rules that the group should

follow at the beginning of the session and is responsible for upholding these

7. Record and action safeguarding concerns in the same way as in other sessions

8. Children and young people should not be in break out rooms ‘unattended’ unless

the session leader feels the quality of the activity would be impacted if a member of

staff was ‘observing’ – break out rooms used in this manner should be utilised

infrequently and for short amounts of time and with the prior approval of the DS

9. Participants should refer to the session leader directly if worried about anything

10. Specific Safeguarding Issues

Radicalisation and Extreme Ideologies

Steve Gregson Photography recognises the positive contribution it can make towards protecting young people from radicalisation to violent extremism. Steve Gregson Photography will empower young people to create cohesive communities built upon shared values, respect, trust and diversity. Steve Gregson Photography also recognises that protecting young people from radicalisation and exploitation is part of our duty of safeguarding and care.

Radicalisation is the process by which individuals come to support terrorism or violent

extremism. It should be remembered that extremism can exist in all sections of society,

regardless of any faith, ethnicity or background. There is no typical profile for a person

likely to become involved in extremism, or for a person who moves to adopt violence in

support of their particular ideology.

Possible indicators are listed below. This is not an exhaustive list:

- Use of inappropriate language

- Possession of violent extremist literature or material (which can include those

accessed by the internet, email and text message)

- Behavioural changes

- Expression of extremist views

- Advocating violent actions and means

- Association with known extremists

- Seeking to recruit others to an extremist ideology

If staff have any significant concerns about a young person, they should discuss this with

Steve Gregson.

Female Genital Mutilation

It is illegal in the UK to subject a child to female genital mutilation (FGM) or to take a child

abroad or aid or abet someone to take a child out of the country to undergo the

procedure. Despite the harm it causes, FGM practising communities consider it acceptable

to protect their cultural identity. The age at which girls are subject to FGM varies greatly

from shortly after birth to any time up to adulthood. The World Health Organisations

(2018) states that FGM normally occurs between infancy and 15.

A young person may disclose that they are at risk of FGM, has suffered FGM or that they

have a family member who is at risk of mutilation.

Staff should be alert to the following indicators:- The family comes from a community that is known to practice FGM

- A child/young person may talk about a long holiday to a country where the practice

is prevalent

- A child/young person may confide that they or a family member is to have a ‘special

procedure’ or to attend a special occasion

- A child/young person may request help from a teacher or another adult

- Any girl/young woman born to a woman who has suffered FGM or has a sister or

relative who has been subjected to FGM must be considered to be at potential risk

Any information or concern about a young person or member of their family being at risk

of FGM must be reported to Steve Gregson as matter of urgency. This may be treated as an

immediate child protection referral to the local authority.

Child Sexual Exploitation

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or

group takes advantage of an imbalance of power to coerce, manipulate or deceive a

young person under the age of 18 into sexual activity (a) in exchange for something the

victim needs or wants, and/or (b) for the financial advantage of increased status of the

perpetrator or facilitator. The victim may have been sexually exploited even if the sexual

activity appears consensual. Child sexual exploitation does not always involve physical

contact; it can also occur through the use of technology.

Like all forms of child sexual abuse, child sexual exploitation:

- Can affect any young person (male or female) under the age of 18 years, including

16- or 17-year-olds who can legally consent to sex

- Can still be abuse even if the sexual activity appears consensual

- Can include both contact (penetrative and non-penetrative acts) and non-contact

sexual activity

- Can take place in person or via technology, or a combination of both

- Can involve force and/or enticement based methods of compliance and may or may

not be accompanied by violence or threats of violence

- May occur without the young person’s immediate knowledge (through others

copying videos or images they have created and posted on social media, for

example)

- Can be perpetrated by individuals or groups, males or females, and children or

adults. The abuse can be a one-off occurrence or a series of incidents over times,

and range from opportunistic to complex organisational abuse

- Is typified by some form of power imbalance in favour of those perpetrating the

abuse- Whilst age may be the most obvious, the power imbalance can also be due to a

range of other factors including gender, sexual identity, cognitive ability, physical

strength, status and access to economic or other resources.

Staff should report any concerns regarding child sexual exploitation to Steve Gregson

immediately.

Online Abuse

Online abuse of children and young people can occur in many ways. The main categories

include:

- Bullying

- Financial Loss

- Online Grooming

- Sextortion (when the victim is blackmailed to hand over money to prevent indecent

photos being posted online/sent to family members and friends)

The main signs and indications that a child or young person may be being exploited online are:

- Spending much less or much more time online

- They behaved differently when they come offline: upset, confused, angry

- Secretive about who they are talking to online

- Have lots of new phone numbers, friends, texts on their digital device

Staff should report any concerns regarding online abuse to Steve Gregson immediately.

11. Reporting and Referring Procedures

When an allegation is made or an instance of potential abuse or harm towards a child or

young person is reported to Steve Gregson, the following procedure will be followed:

1. Steve Gregson will take a detailed account of the allegation from the person or persons

making the allegation.

2. If the person making the allegation is a child or young person, the parent or carer

will be contacted and informed immediately.

3. If Steve Gregson deems the allegation to be criminal offence, the police will be contacted immediately and uptake all responsible for handling the allegation.

4. Where the allegation needs further investigation before disciplinary action or

prosecution is taken, Steve Gregson will take a detailed account from the individual whose alleged misconduct has been reported.

5. Once Steve Gregson is in possession of all relevant accounts, they will assess on a case-by-case basis the relevant bodies to whom the allegation must be reported e.g. the

Local Authority Designated Officer (LADO)

6. Such cases will be handled calmly and confidentially, only involving the minimum

necessary people. Information will only be disclosed to others to whom the

information is relevant or essential and will be done so in consultation with those

involved.

Disclosures

It is recognised that a young person or adult at risk may seek out a specific staff member

to share information specifically about abuse, neglect or self-harm, or a person may talk

spontaneously, individually or in a group when staff or volunteers are present.

In these situations, staff should:

- Stay calm

- Listen, and allow the person to freely recall significant events, keeping questions to

the absolute minimum necessary to ensure a clear and accurate understanding of

what has been said. Ask questions for clarification only; NEVER ask questions that

suggest a particular answer. E.g. ‘When did this happen?’ rather than ‘Did this

happen today?’

- Reassure them but tell them that a record of the information given will be made and

do this. Include timing, setting and others present. Record the person’s demeanour

as well as what is said.

- Explain that they cannot promise to keep confidential anything the young person

says if it relates to child protection or abuse. Staff should not enter into any

agreement with young people to keep disclosed information secret. If any member

of staff becomes aware of any information, which may be a threat to someone’s

wellbeing, they should inform Steve Gregson immediately. Staff can offer reassurance and

commitment to help a young person but cannot offer unconditional confidentiality

to a young person in such circumstances.

- If a young person or adult at risk makes a request to speak to an adult alone this

should never be undertaken in a closed room and the adult should inform other

volunteers where they are.

- Explain that help may be required to keep them safe, but do not ask the young

person to repeat their account of events to anyone else. The information is only

shared if it is necessary to safeguard them.

- Reassure the young person/adult at risk that they have done the right thing in

telling you.

Tell them what you will do next and with whom the information will be shared.
Record, in writing, what was said using the young person or vulnerable adult’s own

words as soon as possible. This should include:

o The young person’s name, address and date of birth

o Date and time of the incidents and/or nature of allegations

o Your observations e.g. describe the behaviour and emotional state of the

child and any physical injuries such as bruising

o The child’s account - if it can be given – of what has happened

o Any action that you took as a result of your concerns e.g. comments made to

the young person, whether the parents/carers have been contacted

o Record whether you are expressing their own concerns, or passing on those

of someone else

o Sign and date the report

o Your name and full contact details – email, telephone and address

This information should immediately be passed on to Steve Gregson who will liaise with the appropriate external agencies. Please note that when a disclosure is made, it is the person to whom the disclosure is made that the authorities (police and/or social services) will come to for an account of what was said. This first-hand account is of primary importance.

It is important that everyone in the organisation is aware that the person who first

encounters a case of alleged or suspected abuse is not responsible for deciding whether

or not abuse has occurred. That is a task for the professional child protection agencies

following a referral to them of concern about a child.